STATE OF FLORIDA EDUCATION PRACTICES COMMISSION CHARLIE CRIST, as Commissioner of Education, Petitioner, vs. ' CASE NO. 001-2135-M DONOVAN E. COLLINS, Respondent. ADMINISTRATIVE COMPLAINT . Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Donovan E. Collins. The Petitioner secks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.2615, Florida Statutes, and pursuant to Rule 6B-1.006, Florida Ad-ninistrative Code, Principles of Professional Conduct for the Education Profession in Florida, szid sanctions specifically set forth in Sections 231.262(6) and 231.2615(1), Florida Statutes. The Petitioner alleges: 1. ‘The Respondent holds Florida Educator’s Certificate 669029, ‘covering the areas of Athletic Coaching, which was valid through June 30, 2000, aad Social Science, which is valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies Teacher teacher at Piper High School School in the Broward Connty School District. “ MATERIAL ALLEGATIONS 3. During February 2001, Respondent made several inappropriate comments of a sexual nature to A-P., a 17-year-old, female student. Additionally, he also sent A.P. a sexually explicit electronic mail, On or about February 13, 2001, Respondent was administratively reassigned pending an investigation. On or about August 2, 2001, the school district issued Respondent a letter of warning and he was return to the classroo:n. col aig el HL DONOVAN E. COLLINS Administrative Complaint Page 2 of 2 STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set for‘h herein are in violation of Section 231.2615(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. . COUNT 2: The allegations of misconduct set for‘h herein are in violation of Section 231.2615(1)(i), Florida Statutes, in that Respondent has viclated the Principles of Professional Conduct for the Education Profession in Florida prescribed by State Board of Education. RULE VIOLATIONS COUNT 3: The allegations of misconduct set fort herein are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in that Responlent has failed to make reasonable effort to protect the student from conditions harmful to leaning and/or to the student’s mental health and/or physical safety. COUNT 4: | The allegations of misconduct set fort herein are in violation of Rule 6B- 1.006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 5: The allegations of misconduct set forta herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Responderit has exploited a relationship with a student for ‘Personal g gain or advantage. 2 “COUNT 6: The allegations ‘fn misconduct set fort’ herein are in violation of Rule 6B- 1. 006(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. WHEREFORE, the Petitioner recommends that the Education Practices Commission “ impose an appropriate penalty pursuant to the authority p-ovided in Sections 231.262(6) and 231.2615(1), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED onthis_ {2 dayof_fe bfw a y , 2002. (Yat. Cu. (Charlie Crist, as (Commissioner of Education, State of Florida Richards, Kathleen From: Stowers, Ron Sent: Wednesday, March 27, 2002 9:56 AM To: Richards, Kathleen; Odom, Tamara; Stowers, [Ron Subject: whitelock formals Be Importance: High kr-- charles whitelock has requested the following 23 cases be sent to doah for formal hearing. chuck will be representing the department in these cases. you do not have to send all of them at once an. it is ok to streach out their delivery to doah over the next 2 to 3 weeks. thanx. robert alonso genear brown isabelle camille donovan collins tobert cooper ivy dominguez gloria forbes ellen goldberg charles harris monica hernandez henry hill sharon horn terrance jett steven kaye gretchen marsh mary mcelrath andrew petter charles redler . harry rolle lynne rushing eric stephens devon tyson reginald white

Docket for Case No: 02-001386PL